ML19270G914
| ML19270G914 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/03/1979 |
| From: | Porter W DUKE POWER CO. |
| To: | |
| References | |
| NUDOCS 7906210126 | |
| Download: ML19270G914 (4) | |
Text
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s In the Matter of
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DUKE POWER COM2ANY
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(Amendment to Materials License
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Docket No. 70-2623 SNM-1773 for Oconee Nuclear
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Station Spent Fuel Transportation
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and Storage at McGuire Nuclear
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Station)
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OBJECTION AND MOTION FOR PROTECTIVE ORDER Pursuant to Rule 2.740 (c), Applicant moves the Board to issue a protective order, and shows as good cause the following :
1.
Intervenor, CESG has forwarded numerous discovery requests to the Applicant, Duke Power Company.
Intervenor CESG's first set of Interrogatories was filed on September 11, 1978; CESG's Request for Admissions from Duke Power Company was submitted on September 29, 1978; two Requests to Produce were filed on November 16, 1978; and further discovery requests were submitted on November 20, 1978, December 18, 1978, and Februa,- 3, 1979.
In each instance, Applicant has replied with detailed and time-consuming response 3.
2.
On April 15, 1979, Intervenor, CESG filed an additional discovery request denomina ted as Question 120.
2240 336 7 906 210/,2(f[.
2.
Applicant has objected to this interrogatory as being beyond the scope of interrogatories.
Question 120 is a hypothetical question which would require Applicant to perform studies and calculations.
Applicant does not have the necessary information to perform the calculations or to answer the question.
WHEREFO RE, Applicant moves for a Protective Order that 1/
the discovery sought by the Intervenor, CESG be denied.
Dated:
May 3, 1979.
Respectfully submitted, William L.
Porter Counsel for Applicant 1./
This motion is filed to protect Applicant's interests in view of 10 CFR 2.740 (f).
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In the Matter of
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I
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a DUKE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials License
)
SNM-1773 for Oconee Nuclear
)
Station Spent Fuel Transportation
)
and Storage at McGuire Nuclear
)
Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Objection and Motion for Protective Order," dated May 3, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail on the 3rd day of May, 1979:
Marshall E.
Miller, Chairman Shelley Blum, Esq.
Atomic Safety and Licensing Board 418 Law Building U. S. Nuclear Regulatory Commission 730 E. Trade Street Washingto n, D. C.
20555 Charlotte, North Carolina 28202 Dr. Cadet H. Hand, Jr.,
Director Bodega Marine Laboratory J.
Michael McGarry, III, Esq.
University of California Debevoise & Liberman P. O.
Box 247 1200 17th Street, N.W.
Bodega Bay, California 94923 Washington, D.
C.
20036 Dr. Emmeth A. Luebke Mr. Geoffrey Owen Little Atomic Safety and Licensing Board Davidson PIRG U.
S. Nuclear Regulatory Commission Davidson College Washington, D. C.
20555 P. O.
Box 2501 Davidson, North Carolina Ms. Brenda Best 28036 Carolina Action 1740 E.
Independence Boulevard Mr. Jesse L.
Riley, President Charlotte, North Carolina 28205 Carolina Environmental Study Group Anthony Z.
Roisman, Esq.
854 Henley Place Natural Resources Defense Council Charlotte, North Carolina 917 15th Street, N.W.
28207 Washington, D. C.
20555 2240 338
Richard P. Wilson, Esq.
Assistant. Attorney General State of South Carolina 2600 Bull Street Columbia, South Carolina 29201 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Atomic Safety and Licensing Board Panel U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Richard K.
Hoefling, Esq.
Counsel for NRC Staff U.
S. Nuclear Regulatory Connission Washington, D.
C.
20555 N
4V William L.
Porter Counsel for Applicant 2240 339